1. SCOPE. This Corporate Travel Policy applies to all suppliers and vendors (“Suppliers”) and all personnel working for Suppliers.

2. AIR TRAVEL. Seagate has signed volume agreements with many travel vendors, including airlines and travel agencies. Suppliers must use Seagate's preferred venders to be reimbursed by Seagate.

a. Seagate Approved Travel Agency. All Suppliers must make all travel arrangements through the Seagate-approved travel agency. Airline tickets purchased through an agency other than the Seagate-approved travel agency will not be reimbursed unless approved in advance by Seagate's CFO.

b. Lowest Logical Fare. Suppliers must use the lowest logical airfare when traveling by commercial airline. The lowest logical rate may require Suppliers to use alternative carriers or airports, such as regional discount carriers or secondary airports. Suppliers will not be required to take the lowest airfare if it adds more than 1 additional interim stop each way, increases the one-way total elapsed trip time (end point to end point) by more than 2 hours or requires departure or arrival changes of more than 1 1/2 hours.

c. Class Of Service. Suppliers must travel in coach class. Exceptions must be requested and granted in advance by the cognizant Seagate Senior Vice President. Suppliers may upgrade airline tickets at Suppliers' own expense. Suppliers may not downgrade airline tickets; any compensation for downgraded tickets must be returned to Seagate.

d. Frequent Flyer Programs. Mileage credits and other benefits from individual frequent traveler programs may be accumulated by Suppliers for personal use; however, Suppliers may not select travel or lodging based on frequent traveler programs.

3. GROUND TRANSPORTATION. Suppliers must use the most cost-effective means of ground transportation. Seagate has a special rate and insurance arrangement with Hertz and National. All car reservations must be made through Seagate's travel agency. Suppliers must rent compact or intermediate size cars unless approved in advance by Seagate. If four or more Seagate personnel, including Suppliers are traveling in the vehicle, or if Suppliers must carry equipment that requires a larger vehicle, the most economical model required to meet the needs of the passengers or equipment should be used. Cars may not be rented for use in the Far East unless approved in advance by the Vice President and country senior Finance Officer. Suppliers must decline all fuel options and return the car with a full tank of gas.

a. Suppliers' Vehicles. Suppliers will be reimbursed for use of Suppliers' vehicles used within Suppliers' scope of work. Mileage is reimbursed in the U.S. at the IRS standard mileage rate, and in other countries at the Seagate rate applicable to that country. Mileage detail must be listed on Suppliers' expense report. Suppliers has the responsibility for properly insuring personal vehicles against damages incurred while in use.

b. Transportation from Home to Airport. Suppliers may use shuttle service for round trip transportation from Suppliers' home to the airport, if the cost of airport parking plus mileage allowance equals a greater amount than the round trip shuttle service. A receipt is required for reimbursement of this expense.

c. Long Term Parking. Suppliers must use long-term parking or off-airport parking.

d. Use of Taxi Service. In the U.S., the daily expense for taxi service must not exceed the cost of a car rental.

4. LODGING. If Suppliers' scope of work requires the use of overnight lodging, Suppliers should use moderately priced single room accommodations. The Seagate Corporate Travel Department has negotiated corporate hotel rates in most major cities. Suppliers must use Seagate's rates. Contact the Seagate-approved travel agency for detailed information regarding individual hotels. All hotel reservations must be made through the Seagate-approved travel agency. Hotel reservations made directly or through an agency other than the Seagate-approved agency will not be reimbursed. Hotels not on the Seagate preferred list will be reserved only if the rate is lower than the Seagate preferred rate. If the Seagate preferred hotel is impractical due to location, the preferred hotel rate will be used as a guideline when reserving alternate accommodations. It is the Suppliers' responsibility to cancel any reservation in a timely fashion in order to avoid a "No Show" charge. Suppliers will not be reimbursed for avoidable "No Show" charges.

5. BUSINESS MEALS. Meal expenses are reimbursable only when overnight travel is required to conduct Seagate business or when a oneday trip takes Suppliers outside Suppliers' normal work location. This includes the cost of breakfast if Suppliers is required to leave home more than two hours earlier than normal and the cost of dinner if Suppliers cannot reasonably return home until two hours or more after normal working hours. Suppliers will not be reimbursed for meal expenses when a commercial carrier provides meal services or when a meal is provided as part of the registration fee for seminars, conventions, etc. Suppliers' meal expenses, including tips and snacks, may not exceed $55 per day, with the following exceptions:

a. North America: The limit in Boston, Chicago, Los Angeles, San Francisco, Hawaii, and Canada is $65 per day. The limit in New York City is $85 per day.

b. Europe: The limit in London is $85 dollars per day. The limit in all other European locations is $65 per day.

c. Asia: The limit in Japan, Taiwan, and Korea is $70 per day. The limit in Hong Kong is $85 per day. The limit in Tokyo is $100 per day.

6. MISCELLANEOUS EXPENSES. Suppliers will be reimbursed for actual expenses for long-distance calls and faxes made within the scope of work. The telephone bill and the name and business affiliation of the individual called must be submitted for reimbursement.

a. Non-Reimbursable Expenses. The following is a partial list of items that Seagate will NOT reimburse:

• Transportation between home and worksite on regular workdays
• Traffic or parking tickets
• Frequent traveler program fees
• Additional travel or car rental insurance costs
• Navigational systems in rental cars
• Credit card and other late fees
• Airline club membership fees
• In-room movies
• Personal items lost, stolen or damaged while traveling
• Transportation, duties, taxes and other fees associated with the shipment of personal effects

CorpTravelPolicy_FRM_GEN_PO_FINAL_092605_44022.doc